UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs (January 2014)
Current · Source: Reserve Bank of India · RBI/2013-14/443 · issued 10 Jan 2014 · ~1 min read
Quick answerRBI directs NBFCs to update and screen customers against the updated UN Al-Qaida sanctions list (twentieth to thirtieth updates) under Section 51-A of UAPA, 1967. New accounts must be checked, and existing accounts must be scanned for matches.
Sanctions-list safety note. This circular refers to a specific UN Security Council / UAPA designated-entities list update as it stood on the date above — sanctions lists change often, and a newer update almost certainly exists today. Never use this page, or any single dated circular, as your current screening list. Always screen against the live, current list at the official UAPA proscribed-organisations list and the UN Consolidated List, and confirm the obligations for your bank on the official rbi.org.in source below.
The rule, in the simplest words
NBFCs (companies that lend money but are not banks) must check every new customer against a list of bad people linked to Al-Qaida (a terrorist group) before opening their account.
NBFCs must also check all existing customers against the same updated list to make sure none of them are on it.
The list to check is the updated 'Al-Qaida Sanctions List' from the UN (United Nations), which includes updates number 20 to 30.
If a customer's name matches the list, the NBFC must not open or keep their account.
How it plays out — a real example
An NBFC compliance officer in Indore, Priya, receives the new UN list from her compliance team. Before approving a new loan for a customer named 'Ahmed Khan', she runs his name through the system and finds no match, so she can proceed. She also runs a scan of all 500 existing accounts and finds one match—she immediately freezes that account and reports it to her manager.
What changed
The UN Security Council's 1267/1989 Committee released updated Al-Qaida sanctions lists covering the twentieth to thirtieth updates. RBI has directed all NBFCs to incorporate these updates into their customer screening processes, referencing a previous circular from October 3, 2013.
What it means for you
NBFCs must immediately update their internal databases with the new UN sanctions list to avoid onboarding or servicing prohibited entities. Non-compliance could lead to regulatory action. This reinforces the need for robust AML/KYC frameworks in the NBFC sector.
What you must do
Download the updated Al-Qaida sanctions list from the provided UN URLs and integrate it into your customer screening system.
Screen all new account applications against the updated list before account opening.
Conduct a retrospective scan of all existing customer accounts to identify any matches with the updated list.
Ensure no account is held by or linked to any entity or individual in the list.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML/KYC teams at NBFCs
❓ Common questions
What is the legal basis for this circular?
This circular is issued under Section 51-A of the Unlawful Activities (Prevention) Act, 1967, which empowers RBI to direct NBFCs to implement UN Security Council sanctions lists.
Where can I find the updated sanctions list?
The updated Al-Qaida sanctions list (twentieth to thirtieth updates) is available on the UN website at the URLs provided in the circular, including http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What should I do if I find a customer on the list?
Ensure the account is not held by or linked to any entity or individual in the list. The source does not specify further actions.
📜 Read the original circular — full text as issued by RBI
RBI/2013-14/443
DNBS(PD).CC. No 366/03.10.42/2013-14
January 10, 2014
All Non Banking Financial Companies /
Residuary Non Banking Companies
Dear Sir/Madam,
Implementation of Section 51-A of UAPA, 1967 -Updates of the UNSCR 1267 (1999) /1989 (2011) Committee's Al Qaida Sanctions List and Consolidated List
Please refer to DNBS (PD).CC.No 358/03.10.42/2013-14 dated October 3, 2013 . The Chairman of UN Security Council's 1267/ 1989 Committee has since issued the updated “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida. The updates from twentieth to thirtieth update are available on UN website at the following url:
http://www.un.org/News/Press/docs//2013/sc11099.doc.htm
http://www.un.org/News/Press/docs/2013/sc11089.doc.htm and
http://www.un.org/News/Press/docs//2013/sc11117.doc.htm
2. All NBFCs are required to update the list of individuals/entities as circulated by Reserve Bank and before opening any new account, it should be ensured that the name/s of the proposed customer does not appear in the list. Further, NBFCs should scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list.
3. The complete details of the said list are available on the UN website:
http://www.un.org/sc/committees/1267/pressreleases.shtml
http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml
http://www.un.org/sc/committees/1267/delisting.shtml
Yours faithfully,
(Sindhu Pancholy)
Deputy General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2013-14/443 · issued 10 Jan 2014. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before account opening.
💻 IT / Systems
Download the updated Al-Qaida sanctions list from the provided UN URLs and integrate it into your customer screening system.
📜 Compliance
Conduct a retrospective scan of all existing customer accounts to identify any matches with the updated list.
Ensure no account is held by or linked to any entity or individual in the list.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are an IT/Systems lead at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML/KYC teams at NBFCs), your first concrete step on “UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs (January 2014)” is: “Download the updated Al-Qaida sanctions list from the provided UN URLs and integrate it into your customer screening system.” (RBI issued this 10 Jan 2014).
Circular: RBI/2013-14/443 -- UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs (January 2014)
Issued: 10 Jan 2014
Action required: Download the updated Al-Qaida sanctions list from the provided UN URLs and integrate it into your customer screening system.
Action required: Screen all new account applications against the updated list before account opening.
Action required: Conduct a retrospective scan of all existing customer accounts to identify any matches with the updated list.
Action required: Ensure no account is held by or linked to any entity or individual in the list.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=8688&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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